The first wave of mandatory sustainability reporting — driven by CSRD in Europe, ISSB-aligned frameworks in the UK, Australia, Singapore and elsewhere, and IFRS S1 and S2 adoption across forty jurisdictions — is beginning to produce a measurable shift in corporate disclosure practice. A new study published this week by the International Federation of Accountants, the American Institute of CPAs, and the Chartered Institute of Management Accountants confirms the shift is real, but documents significant unevenness in how ready companies across different geographies and sizes are to respond to it.
The study reflects what practitioners have observed since the first CSRD reports were filed: the gap between regulatory obligation and reporting capability is not evenly distributed. Large, well-resourced multinationals with established sustainability functions have generally been able to meet mandatory requirements, even if the process was operationally demanding. Mid-market companies — many of whom entered CSRD scope only this year under the original thresholds — have struggled more with data collection, double materiality assessments, and the gap between what they measure internally and what the standards require them to disclose publicly.
The ESRS revision adopted last week will ease some of that pressure for the next wave of reporters. The reduction in mandatory datapoints and the stronger materiality filter give mid-market companies more room to calibrate their disclosures to what is genuinely material for their business. But the IFAC-AICPA-CIMA study is a reminder that simplification of the standards is only one dimension of preparedness. Assurance capability, data systems, and internal sustainability governance are equally consequential — and those cannot be simplified by delegated act.
Sources: Mandatory sustainability requirements begin to impact global reporting — AICPA-CIMA